Welcome….

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Minnesota is rich in blogs, and rich in alternative media such as The Uptake and Daily Planet.  Is another blog really needed?  Good question!   My main reason for setting it up is to have a place to archive and link to various emails and posts I’ve sent about Minnesota environmental issues. Continue Reading →

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“U.S. taxpayers help fund oil-train boom amid safety concerns”

http://www.stltoday.com/business/local/u-s-taxpayers-help-fund-oil-train-boom-amid-safety/article_cd09f5c9-9c34-505b-a5dc-3abca7d069ce.html

As a follow up to the bridge story, see this piece from Reuters.

Minnesota is one of the states that has been somewhat forthcoming about oil train traffic.

Minnesota (MNDot) is in the process of developing a 2015 state rail plan.  This is in response to a federal requirement.  I attended a meeting about it in Red Wing but went away feeling less than fully enlightened.

 

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“Railroad bridge conditions hidden from public view”

Images:  Railroad bridges along the Mississippi River

http://lacrossetribune.com/news/local/railroad-bridge-conditions-hidden-from-public-view/article_23e95758-fbbd-58ae-af31-619a3d4b4518.html

An important story on rail bridges was published on December 14th in the LaCross [WI] Tribune.  Byline:  Chris Hubbuch.   We understand this story was instigated by Guy Wolf, Alan Stankevitz, Irv Balto, and other leaders of Citizens Acting for Rail Safety (CARS).   CARS gave extensive briefings to Wisconsin Senator Tammy Baldwin and other public officials, and provided much of the information and many of the images used in the story. Continue Reading →

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Citizens’ Board does a good thing; Powers of Darkness push back; Action Alert

Feedlot Action Alert, and: Update: “Strange nonsense at the Minnesota Environmental Quality Board (and the MPCA)”

In June I did a post critical of the MN Environmental Quality Board and the Minnesota Pollution Control Agency, suggesting that the environment of Minnesota isn’t being protected very well.  The email of this post had a higher readership than any other I’ve written.  One friend called it “very depressing.”  It garnered me some disapproving looks from EQB and Citizens’ Board members.  What’s happened since?

(The rest of this post relates to the MPCA and it’s Citizens’ Board.  In my view the EQB is looking like a train wreck, but that’s for another post.) Continue Reading →

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Pretty sky but the transmission lines need a lot more thought….

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“Giving Tuesday” and all that….it’s my turn for an “ask”

Today is one of those days when we get many emails asking for contributions. As Bill McKibben says ‘Today is “Giving Tuesday’, which is a charitable rebuttal to the madness and materialism of ‘Black Friday'”.

Below is just a selection from today’s inbox:

“Help us fight for justice, fairness and equality”
“For Giving Tuesday, be a polar bear’s hero”
“We need you on #GivingTuesday”
“Be a Waterfront Champion on #GivingTuesday”
“Celebrate #GivingTuesday with ADA”
“Help us fight for justice, fairness and equality”
“It’s Giving Tuesday! Please help”
“This Giving Tuesday, give critters a place to roam”
“It’s #GivingTuesday! Join the Global Movement”

Most of the orgs asking for contributions do good work and deserve contributions. But having been an environmental campaigner/consultant for a long time, I’ve formed some strong views, including these: Continue Reading →

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Passing of Jan Greenfield

Jan’s obit as it appeared in the Strib:

Janice Naomi Greenfield
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Greenfield, Janice Naomi age 72, of St Paul. A devoted and conscientious mother to two sons, a friend to a host of diverse people, an ardent environmentalist who loved to hug trees, and an accomplished folkdancer, contradancer and English Country dancer, Jan died in her home from lymphoma on Sunday morning, 26 Oct 2014. As a mother she modeled friendliness, diligence, intellectual curiosity and acceptance of others; as a spouse she coaxed her husband into becoming a better man; as a friend she was reliable, loyal and forgiving. She departed this life in the same honest and principled manner as she had lived it, and was buried in a simple ceremony on 27 October with six of her immediate family in attendance. Jan is survived by her former spouse Roger Forsberg, sons Brian (Heather) and Jev (Rachelle), brother and sister-in-law Walt and Angie Greenfield and several cousins, nephews and nieces. Memorials preferred to Tapestry Folkdance Center (Minneapolis).

Jan made great contributions to the fight against a waste burner at the Rock-Tenn plant in St. Paul, against increased burning of garbage at the “HERC” incinerator in Minneapolis, and against the proposed  “eco-crapper” wood burner on Lake Street in Minneapolis.  All these fights were successful.

Jan was also very concerned about unnecessary electromagnetic field exposures from “smart meters.”

She maintained several websites for advocacy efforts.

The range of her interests and activities was wide–I didn’t know about them all by any means.

Jan was an exceptional person.  She put her life energy into working to make our world a better place.  She was much loved and will be much missed.

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The “Burner County” resource page–resources to better understand why Hennepin County owns, and Covanta operates, the “HERC” garbage incinerator in Downtown Minneapolis, MN

Here are links to various documents, some found on the official Hennepin County website, some found elsewhere, and some obtained by means of MN Data Practices Act (“Freedom of Information”) requests.  This is a work in progress and we will be adding to it.  If you have documents to contribute to the effort, please send them to Alan Muller, alan@greendel.org

(There are also many important HERC documents on the website of Minneapolis Neighbors for Clean Air.)

My letter to the Hennepin County board about HERC concerns.  Includes links to background documents…. This letter contains various important questions we hope the County will provide meaningful answers to.

Contract for hiring the Washington, DC law firm Morris, Manning & Martin for $50,000 in connection with HERC contract extension. Obtained from Hennepin County via Data Practices Act.

Agreement between Hennepin County and HDR Engineering for services related to negotiating a 20-year extension of the “service agreement” with Covanta for operating the HERC garbage burner. Cost: $139,408.   Obtained from Hennepin County via Data Practices Act.

The following two documents need to be looked at together.  One is the “Board Action Request,” giving a “TOTAL NET AMENDED NOT TO EXCEED $407,163,484.00″  The second is the text of the Amendment with an attached list of actual projects.

http://www.alanmuller.com/wp-content/uploads/2014/11/Board-Action-Request-Amd-5-to-HC-service-agreement-with-Covanta.pdf

http://www.alanmuller.com/wp-content/uploads/2014/11/amendmentfivetoserviceagreement.pdf

This is a page extracted from the 342 page Hennepin County CBTF [Capital Budget Task Force] Recommended: 2015-2019 Capital Improvement Program. The full document is likely available on the Hennepin County website here: http://www.hennepin.us/your-government/budget-finance/budgets, but I am not attempting to link to the specific document as things seem to keep moving around.

http://www.alanmuller.com/wp-content/uploads/2014/11/page-from-2015-capital-budget.pdf

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A detailed review of every contaminated site in Minnesota is urgently needed….

One of the best elected officials I know of is Cam Gordon of the Minneapolis MN City Council.  Gordon is a Green Party member, one of a relative handful of official Greens holding office in the United States.  I don’t agree with all Gordon’s positions, of course, but he shows an impressive ability to maintain independent and thoughtful positions while seeming to maintain working relationships with his colleagues. In March, 2014, Gordon posted this commentary (below) on one of the more consequential environmental scandals to surface recently in Minnesota. Continue Reading →

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Public comment time on MN air monitoring plan

“Air Monitoring” touches on many localities and many issues.   Whether the concern is high asthma rates in North Minneapolis due to dirty air, or disease-causing silica dust from “frac” sand mining, or “regional haze” limiting views in the Boundary Waters Canoe Area, or coal and “biomass” burner emissions sickening and killing millions of people worldwide, or toxic fumes in a basement because a contaminated site was never really cleaned up, measuring the actual composition of our air is a key step in the chain of events that need to happen to improve it.

Monitoring in a broad sense can be aimed at measuring the overall state of the air (“ambient” monitoring), the impacts of a particular facility (“fenceline” monitoring), what is coming out of a particular smokestack (“continuous emission monitoring” or “performance testing”), the air quality in your home or workplace (radon testing, for example), or wearing a personal air monitor for a day to determine individual exposure.   It might be a “bucket brigade” monitoring program organized by a community organization.  It might be other things.

People tend to assume that if they are concerned about bad air, monitoring will confirm the problem.  This may or may not prove to be the case.  Often it does not, because “the devil is in the details” and the details of air monitoring are very complex and not easy to understand.

Based on incomplete information provided by the Pollution Control Agency (MPCA), it appears that about 64 cents per person per year is being spent on air monitoring in Minnesota.  (Half or more of the money is federal in the form of grants from EPA,)  Are we getting what we need from that expenditure?

The MPCA has estimated that human-caused (“Anthropogenic”) PM-2.5 (fine particle) air pollution is killing 3800 Minnesotans per year, sending 940 to the hospital, sending 770 to emergency rooms, causing 260,000 lost work days, causing 1600 non-fatal heart attacks, and so on.   The same report estimates that ozone pollution is killing another 61 Minnesotans per year, sending 440 to the hospital, causing 140,000 missed school days, and so on.  The MPCA estimates the cost of all this death and disease at about $35 billion.  Of course, there are many other types of air pollution also causing harm, and the estimates must be considered very approximate.  (The MPCA seems to value a human life lost at about $900,000.  How much do you think yours is worth?)  In any case, these numbers suggest that the annual cost per living Minnesotan is about $6290 per year, about ten thousand times the amount being spent on monitoring the quality of our air.

Most air monitoring in Minnesota is done by, or with the advice of, the Minnesota Pollution Control Agency (MPCA), and is a fairly narrow subset of the whole world of monitoring.  As required by the US Environmental Protection Agency, a 30 day public comment period was held during June.  At the request of people, the comment period was extended to Aug 1, 2014.  But, the PCA says it will accept comments at any time.

See Action Alert: Ask for public comment extension on Minnesota air monitoring plan.  In this I tried to point out some of the concerns and issues around monitoring.

In response to Data Practices act requests, the MPCA provided information on grants and budgets.  Some examples:

“Near Roadway NO2 Monitoring Site Establishment Grant” (USEPA, $200,000)
“Particulate Matter (PM 2.5) Air Monitoring Network Cooperative Agreement” (USEPA, $1,324,694)

This is from an alert I received this morning [Let me know if you want the whole thing in order to act on it.]

” … Tell the Winona Mayor and City Council members to require air monitoring at all frack sand mines, processing, and transportation facilities in the city of Winona. They may consider the monitoring at their meeting 6:30 pm on Monday, August 4.”

“I believe that without monitors at the fence lines of each facility, residents and visitors have no idea whether they are at risk from the crystalline silica dust these facilities produce.”

The [Citizens Environmental Quality Committee (CEQC)] has 3 times made their recommendations to the City’s Planning Commission.  Each time they have been rejected as unnecessary and too costly for the operators of these facilities.  The CEQC now wants the Mayor and City Council to consider their recommendations directly.

Many people in North Minneapolis have expressed concern about the movement or shutdown of an air monitor.

Many people were concerned when they found out there was NO ozone monitor in Minneapolis or St. Paul.

People are concerned that pollutant “spikes” as reflected in real-time data but are not recorded.

Some thoughts from Muller:

Minnesota needs to take a broad look at air monitoring to ensure that real needs are being met and that adequate funding is available.

These real needs include, for example, helping people who are being sickened or stunk out of their homes by neighbors’ wood stoves or backyard boilers.  This might involve personal exposure monitoring.   The MPCA and MDH should be prepared to respond in a substantial and meaningful way.

The MPCA and the Minnesota Department of Health need to be more proactive in regard to air monitoring in Environmental Justice communities.  Consultation with EJ communities is needed to work out the details.

Monitoring is not being recorded in small enough time intervals to detect “spikes” of pollutants that may cause health effects.  Even one-hour intervals are probably not small enough.  Not enough monitoring data is available in real time on the Internet.

There are two non-routine air monitoring projects related to North Minneapolis, the “Community” project and the “ North Minneapolis” project instigated by the Northern Metals permitting controversy.  These may be very distinct internally to the MPCA but are likely to be less so to community members.  The results of these two efforts should be integrated to the extent possible.

The “detailed results” of the “North Minneapolis” project contain more detail on wind directions & etc.  It would be desirable to present this information in the same level of detail for the “Community” project.

In general, air monitoring tends to focus on compliance, and to a lesser extent research and enforcement.  More direct emphasis on health protection is needed.

A major concern is the focus on presenting 24 hour data as if the point was to establish, or imply, compliance with the 24-hour PM-2.5 standard of 35 micrograms per cubic meter.  It is repeatedly stated that the 24 hour averages of measured concentrations are below the National Ambient Air Quality Standards (NAAQS).  This seems intended to imply that air quality problems aren’t present, at least for PM-2.5

Looking at the raw (but QCd) data for the North Minneapolis (31st Ave N. & N. Pacific Street) monitor from Jan 1, 2013 to March 31, 2014, it appears that there were 115 hourly intervals during which PM-2.5 concentrations were above 35.  For 31 hours they were above 50.  For five hours they were above 70.  The peak value was 126, at 6:00 PM on May 14, 2013.  For 370 hour intervals no results were recorded because the equipment was not working properly.

It is well-demonstrated in the literature that air pollutant levels below the National Ambient Air Quality Standards produce health effects.  There may be a “Linear No Threshold” relationship.  It is well known that the setting of air quality standards are influenced by political considerations (influence of big polluters, Chamber of Commerce ….) and the setting of standards lags behind what the scientific literature has to say, sometimes by many years.   Health data–asthma, etc–for neighborhoods in Minneapolis strongly suggest that air quality is impacting human health.  The PCA itself, in a presentation to a legislative committee, has estimated widespread health effects as noted above.

Minnesota is hone of the highest radon level states because uranium is widely distributed in the states complex geology.  The EPA “action level” of 4 picucuries per liter corresponds to an estimated lung cancer death rate of one in seven thousand, a much higher risk level than typically considered acceptable.  (The World Health Organization recommended level is 2.7.)  An EPA presentation estimated that 564 Minnesotan’s per year die of radon-related lung cancer.  Radon deaths can be prevented, or greatly reduced, by testing homes for radon and installing “mitigation” systems to suck out the radioactive gas.  The cost per life saved has been estimated at $190,000.  The cost of treating a case of lung cancer has been estimated at one million dollars.  As noted above, the MPCA estimated the value of a human life lost to air pollution as about $900,000.  These facts make clear that it would be highly cost-effective for Minnesota to ensure that every home in the state is tested for radon and mitigated if radon levels above 2.7 are found.

(Radon is the “turf” of the Minnesota Department of Health and not the Pollution Control Agency, and is outside the formal scope of the “network plan” the PCA seeks comment on–although, at the federal level, radon seems to be the turf of the EPA.)

A quick review of the “2012 Criteria Point Emissions Ranking Report” indicates that many of the grossest belchers are part of or connected to mining.  (Including Minnesota Power as the primary supplier of electric power to mining facilities.)  For example 7 of the top 10 NOx emitters, 8 of the top 10 Particulate Matter emitters, 5 of the top 10 sulfur dioxide emitters, and 3 of the top 10 lead emitters are mining-connected.  This strongly suggests that instead of an ongoing “free ride,” mining and mining-related facilities should be targeted for monitoring and permit tightening.

Minnesota needs to be more pro-active in setting state-level standards below national standards when “the science” and local needs support doing so.

Conclusion:

The monitoring plan on which the MPCA has sought comments is very complex, but in reality describes only a part of the air quality monitoring Minnesota really needs as part of a serious effort to improve air quality and public health.

Tell the MPCA what YOU think:  rick.strassman@state.mn.us .

Alan Muller

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Action Alert: Ask for public comment extension on Minnesota air monitoring plan

“Air monitoring” is really “air pollutant monitoring” and means measuring known-to-be-harmful substances in the air we breathe.  This sounds simple but is not.  Often enough we are not measuring what we really should be measuring, or are not given correct interpretations of the results.

In Minnesota, most air monitoring is done by the Minnesota Pollution Control Agency (MPCA).  The primary motivation of the MPCA is to show that air quality is OK.  The conflict of interest is obvious in that the MPCA issues the “permits to pollute” and is not motivated to admit that the resulting emissions cause problems.  That said, there is more monitoring of air pollutants in Minnesota than some other places and some monitoring goes beyond federal (Clean Air Act) requirements.  [Note:  I’m talking about the collective motivation of the MPCA under the political direction it gets.  This does not speak to the personal motivations of the staff, many of whom do care about “pollution control.”]

Monitoring is technically complicated and often the data can be interpreted in different ways.  For example, the MPCA may say that the “24 hour average” concentration of a pollutant is below the National Ambient Air Quality Standard.  This may be intended to give the impression that air quality is OK and people should stop worrying and complaining.  But within that 24 hour average could be “spikes” of intense pollution that are, in fact, making people sick.

In general, it is assumed that the air is OK to breathe unless measurements prove otherwise, even if you are under a giant industrial smokestack.  So, air polluters like less monitoring.  Some people could suspect the MPCA of putting monitors where the pollution ISN’T, and avoiding putting them where the pollution IS.  For example, some were surprised to learn that there were no ozone monitors in Minneapolis or St. Paul.  There are no monitors in Benson, MN, although the MPCA has issued permits there for an ethanol plant and a turkey litter incinerator, in spite of the fact that exceedances of air quality standards were predicted.  There are no monitors in Perham, where an unpermitted facility was predicted to cause exceedances of air quality standards, and where the MPCA has promoted, permitted, and partially paid for an expanded garbage incinerator.  Is anyone really protecting the health of people in Benson or Perham?

Evidence is piling up of health damage from air pollutants at far below the legal “standards.”  (It is very hard to lower standards because industrial and electric utility interests lobby against it, and these have far more money than health/environmental interests.)  For example, on March, 2014 the Guardian reported:

“Air pollution has become the world’s single biggest environmental health risk, linked to around 7 million � or nearly one in eight deaths in 2012 � according to the World Health Organisation (WHO).

The new figures are more than double previous estimates and suggest that outdoor pollution from traffic fumes and coal-burning, and indoor pollution from wood and coal stoves, kills more people than smoking, road deaths and diabetes combined.”

From a post last AprilAn MPCA report, based on EPA methodology used to estimate the cost-effectiveness of air regulatory programs, estimates that all man-made PM2.5 pollution is killing 3,800 people per year in Minnesota, those lost people being worth 34 billion dollars.  The Minnesota PM2.5 emissions alone are estimated to be killing 1,600 people per year, those lost people being worth $14 billion dollars.  Of course, many more people are made sick but survive.  For example, Minnesota PM 2.5 emissions alone are estimated to be causing 460 non fatal heart attacks per year, worth forty nine million dollars per year.” (Thanks to Rep. Jean Wagenius for asking for this report.)

The MPCA, along with industrial polluters, is funding a campaign to prevent the US EPA from finding Minnesota in “non-attainment” of the ozone air quality standard.  This, perhaps with intentional humor, is called the “Clean Air Dialog” or “Clean Air Minnesota,” and is run by an industrial front–“astroturf”–group calling itself “Environmental Initiative.”  The funders of this scheme are listed as 3M Company, Flint Hills Resources (the big Koch Brothers oil refinery) and the MPCA.  See the Role of Shame of participants.  Of course, “non-attainment” would be the best thing for air quality in Minnesota because it would force some serious planning and regulating for cleaner air.  For our purposes here we need to wonder whether an agency seeking to evade “non-attainment” can really be trusted to monitor ozone levels. [Note:  The current version of the “Clean Air Minnesota” scam is less blatant about the objective of evading non-attainment, but the real objectives haven’t changed.]

Every year the MPCA is required by the US Environmental Protection Agency to open a 30-day public comment period on an “Annual Air Monitoring Network Plan for Minnesota” for the upcoming year.  Few people comment on this; few people know about it.  It is not easy to understand what it really says.  (One regular commentor is Cliffs Natural Resources, operators of a taconite plant in Silver Bay, North of Duluth.  They don’t want monitoring for asbestos in the air)

But, interest in air monitoring is growing.  People in North Minneapolis want to know if their air is making them sick.  People want to how much frac sand dust is in their air, or could be.  People are tired of breathing wood smoke pollutants, “biomass” burner pollutants, coal plant pollutants, feedlot pollutants, traffic pollutants ….

It is reasonable to ask whether the proposed “monitoring plan” responds adequately to these concerns.  The 44 page draft plan was published on June 2nd with a public comment period extending to July 1.  We immediately responded with a Data Practices Act request for more information:

The PCA has just issued a public notice of opportunities to comment on the draft 2115 state Air Monitoring Plan.  I expect to do this as I have done in the past.

The plan document contains considerable technical information but little if anything about the budget for air quality monitoring.   However, it has been otherwise stated that funding limitations have had impacts on air monitoring in Minnesota.

Therefore, pursuant to the MN Data Practices Act, I request a summary of the funds allocated to air quality monitoring in Minnesota from 2004 to 2014, including total amounts and sources (state/federal, etc).  I also request all documents that speak to the adequacy, or otherwise, of this funding, and impacts of funding limitations on the extent of monitoring statewide.

This request also includes all grant applications, and/or grants received, for air monitoring and related activities.

This request also includes all requests for air quality monitoring in Minnesota received by the MPCA between 2004 and 2014, and the disposition of those requests.

This request also includes all correspondence between the MPCA and the Minnesota Department of Health, the Department of Public Safety, or other Minnesota entities, on or related to the subject of air quality monitoring.

This request also includes all correspondence between authorities in Wisconsin, Iowa, South Dakota, North Dakota, Manitoba, Ontario, the Canadian federal government, and the USEPA, and other US federal agencies, and regional/cooperative bodies including the International Joint Commission, regarding air quality monitoring in Minnesota, during the past five years.

This request also includes any presentations to or correspondence with the Legislature regarding air quality monitoring during the last five years, including budget requests.

My intent is to use this information to develop responsive comments are requested by the MPCA.  Given that:

“Public Comment Period Begins: June 2, 2014″
“Public Comment Period Ends: July 1, 2014″

Time is of the essence in receiving the requested materials.  Please contact me if any clarifications are called for.

Some but not all of this information has been provided.  The info on funding has not arrived.

At least four pages of the report make reference to monitoring being shut down or not started up due to funding limitations.

I sounded out the MPCA on extending the public comment period and was basically told “not if just you are asking for it.”

So, here’s the action part of this Action Alert:  Ask the MPCA to extend, or reopen, the public comment period on the air monitoring plan for at least 30 days, and provide all requested information (we will post it all):

Contact:

John Linc Stine, Commissioner, MPCA: John.Stine@state.mn.us , 651-757-2014
Susan Hedman, Regional Administrator, EPA Region 5 (Chicago): hedman.susan@epa.gov , 312.886.3000
Rick Strassman, MPCA:  Rick.Strassman@state.mn.us , 651.757.2760
your Minnesota Senator and Representative: Who Represents Me?

Alan Muller

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